2018 Trends In HHS Corporate Integrity Agreements

By John Bentivoglio, Jennifer Bragg and Maya Florence (January 16, 2019, 1:45 PM EST) -- While the number of new corporate integrity agreements declined since 2017, and was below the trailing five-year average, 2018 was an important year on the policy front for the Office of Inspector General at the U.S. Department of Health and Human Services. The HHS OIG rolled out a new fraud risk indicator and related transparency initiatives aimed at companies that refuse to enter into CIAs following a civil health care fraud settlement. Entities negotiating CIAs are likely to experience a tougher, less flexible approach from the HHS OIG as it continues to rely on model agreement templates as the starting point in CIA negotiations. If recent history is a guide, companies that violate existing CIAs may face stiff stipulated penalties for such breaches....

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